Ontario’s New Pay Transparency Law: What Every Employer Needs to Know Right Now

The Rules Have Changed. Is Your Hiring Process Ready?

As of January 1, 2026, hiring in Ontario is fundamentally different. The Working for Workers Four Act (Bill 149) has come into force, and it brings mandatory obligations that every employer — regardless of size, sector, or hiring volume — needs to understand before posting their next role.

If you have 25 or more employees and you’re publicly advertising a position in Ontario, these rules apply to you. Non-compliance isn’t just a reputational risk anymore. It’s a regulatory one.

What You Must Now Disclose in Every Job Posting

The new legislation introduces four core requirements for any publicly advertised role in Ontario:

There is also a post-interview obligation: you must inform any candidate who was interviewed whether a hiring decision has been made, and you must do so within 45 days of their last interview. Initial phone screens are excluded from this requirement, but in-person or video interviews are not.

Record-Keeping Is Now a Legal Requirement

Beyond the posting requirements themselves, the legislation mandates that employers retain copies of all publicly advertised job postings, associated application forms, and candidate communications for a minimum of three years after the posting is removed. This is not optional documentation — it’s a compliance obligation that your HR team needs to build into its workflows now.

What This Means in Practice for HR Teams

For many organizations, the immediate challenge is internal. Compensation structures that have never been formalized now need to be documented and made defensible. Pay ranges that were historically kept fluid to give hiring managers negotiating room must now be set, justified, and disclosed. The legislation does not require you to explain how you arrived at your range, but it does require the range to reflect what you would realistically offer.

That data point matters. Pay transparency isn’t just a legal checkbox. Done right, it’s a competitive advantage. Candidates who see honest salary ranges apply with more realistic expectations, convert better at the offer stage, and onboard with greater satisfaction.

The AI Disclosure Clause — A Closer Look

The requirement to disclose AI usage is straightforward in principle but nuanced in practice. You are not required to name the specific tools you use or describe how they function. A statement such as ‘This employer uses artificial intelligence technology to assist in screening, assessing, or selecting applicants for this position’ satisfies the obligation.

However, simply adding that line without reviewing how your tools actually work introduces its own risk. If your AI systems haven’t been audited for potential bias in candidate evaluation, now is the time to conduct that review. Transparency about using AI is a first step. Ensuring that AI is being used responsibly is the expectation that will follow.

How CAN X Global Helps Employers Navigate This

Compliance shouldn’t slow down your hiring. The team at CAN X Global stays current with all legislative changes affecting recruitment in Canada so that our employer partners don’t have to manage this in isolation. From building compliant job posting templates to advising on salary benchmarking and disclosure strategy, we work as an extension of your HR team — keeping your process clean, legal, and competitive.

For employers who use CAN X Global’s recruitment services, all candidate communications and posting records are managed to meet the new retention standards. That’s one less operational burden on your internal team.